Failures and Successes When Implementing a Non-ISO 14001 EMS at a University and Medical

Center

A Wee Bit of History

• Back in the early 2000s, EPA inspected a number of Region I and II College & Universities

• Resulted in Consent Agreements with agreements to develop an EMS at several schools.

• Environmental Programs decided to be proactive and develop an EMS before Region IV started inspections

Starting the Development Process

• Received special project $$$$ from University

• Hired new employee (actually stole her from safety group)

• Utilized students to facilitate the adoption of the Duke University Environmental Policy – signed Earth Day 2005 (18 month process)

Developed an EMS Vision

Duke has created a comprehensive environmental initiative to incorporate environmental issues into campus decisions and actions – everything fromthe paper you print on to the way buildings are designed.

Set Overall Project Goal

Develop an performance-based EMS to:

• focus environmental initiatives within key areas,

• measure improvement and routinely track and report progress.

EMS Development Objectives

• Develop a campus-wide system that can be utilized by all stakeholders.

• Create an initiative to integrate environmental performance into the campus work culture.

Engaged Campus Organizations

• EMS Planning Committee

• OESO • EMAC – the Environmental

Management Advisory Committee

• DUGI – Duke University Greening Initiative

• EA – Environmental Alliance

• Facilities Management Department

Duke’s Strategic Partnerships

NC DENR Environmental Stewardship Initiative

Labs 21

U.S. Green Building Council Member

EPA’s Green Power Partnership

EPA’s College and Universities Sector Strategies Program

Hospitals for Healthy Environment (H2E)

Camp, Dresser and McKee CDM

Balanced Scorecard Strategic Focus

CustomersCustomersInternalBusinessPractices

InternalBusinessPractices

Learning & Growth

Learning & Growth

Financial Financial

Strategy

A Framework to Integrate Environmental Performance into Management Decisions The Balanced Scorecard

The Balanced Scorecard -• Translates vision and strategy

into operational terms• Focuses, links and aligns an

organizations actions and strategic plans to the institution’s goals

• Makes strategy everyone’s job• Makes strategy a continual

process

Vision & Strategy

Feedback andlearning

Planning andtarget setting

Communicatingthe vision

Review

Focuses, links and aligns an organizations actions and strategic plans to the institution’s goals

Environmental Balanced Scorecard Strategic Focus

ComplianceComplianceConservation & Preservation of

Resources

Conservation & Preservation of

Resources

Learning & AwarenessLearning & Awareness

Sustainability Sustainability

PerformanceStrategy

StewardshipStewardship

Translating the Vision -Focus Performance Improvement in 5 Key Areas

• SUSTAINABILITY – Meet the needs of the present without compromising the ability of future generations to meet their needs.

• COMPLIANCE – Achieve and sustain compliance through good management practices.

• STEWARDSHIP – Less overall environmental impacts by developing & promoting practices that maximize beneficial effects and minimize harmful effects of research, operations, & activities

• RESOURCE CONSERVATION – Utilize, conserve, and restore natural resources in ways that ensure long term social, economic, and environmental benefits.

• EDUCATION & RESEARCH – Increase faculty, staff, and student awareness; enhance environmental educational offerings, support research and disseminate information regarding research opportunities.

Defining Strategic Measures

Sustainability

Compliance

ResourceConservation

Awareness

Stewardship

Sustainability

Compliance

ResourceConservation

Awareness

Stewardship

GHG Reduction

Reduced Solid Wastes/Increased

Recycling

ReducedHazardous

Wastes

Reduced water Consumption

Energy Use

GHG Reduction

Reduced Solid Wastes/Increased

Recycling

ReducedHazardous

Wastes

Reduced water Consumption

Energy Use

Performance Improvement

Areas

Institutional Success Measures

Environmental Performance-Based Organization

Office of the President

Office of the President

EnvironmentalPolicy

EnvironmentalPolicy

Key performanceareas

Key performanceareas

Senior Vice President’s

Office

Senior Vice President’s

Office

Environmental Management

Advisory Committee

Environmental Management

Advisory Committee

Environmental Project Implementation

Teams –OESO, DUGI, Procurement, Labs,

Academic Units, Departments, ,etc.

Environmental Project Implementation

Teams –OESO, DUGI, Procurement, Labs,

Academic Units, Departments, ,etc.

Success indicators

Success indicators

OESOOESO

Improvement projects and initiatives that

align with performanceareas & link to indicators

Improvement projects and initiatives that

align with performanceareas & link to indicators

Align with focus areaAlign with focus area

Link to Success indicator

Link to Success indicator

Opportunitiesidentification

EMS website

Stakeholderinput

Audits &assessments

Support

Annual report

Annual report

Developsprojects

Developed Implementation Plan

Implementation Action Items• Distribute implementation guide,• Build remaining system components, • Launch awareness campaign,• Develop communication strategy,• Complete website,• Develop annual environmental report• Complete linkage of EMS and EMAC to the administration• Develop a long-range funding plan

Pilot Projects• Mercury Reduction Initiative• Recycling Initiative• Energy Use Reduction in Laboratories• Water Use Reduction In Dormitories

Successes & Failures

• Environmental Policy signed • Pilot projects were implemented • EMS was reviewed by State Environmental Stewardship

Initiative – panned plan for not conforming specifically to ISO 14001.

• EMAC committee never truly ‘bought in’ to the EMS process.

• Chairman not engaged• Committee eventually fell apart

• With no committee and “driver” for project, lost support and Campus-wide EMS faded into history

If first you don’t succeed…..

• EPA College & University Initiative required an EMS or audit the facility every two years……

• New EMS Team formed in 2012 – 3 OESO personnel and 1 outside consultant

• Restated Campus-Wide Performance Goal • To achieve, exceed, and sustain long-lasting compliance to

relevant and applicable environmental rules and regulations

• Stated from start – compliance to ISO 14001 not a goal…..a functioning EMS is

Environmental Compliance Management System

• Focus on meeting and exceeding compliance hence the ECMS name

• Elements of system– Environmental Policy– Planning– Implementation and Operation– Checking and Corrective Actions– Management Review

Environmental Compliance Management System

• Recycled and updated a number of processes and plans developed during original EMS development

• Additional Items developed • extensive Regulatory Compliance Calendar• Training Matrix• Numerous SOPs (i.e. internal audit, operational control)

• The ECMS management will remain within OESO EP not with a committee

ECMS Organizational Structure

Roles

Advisory Committee

OESO

Departments/Facilities

Admin.

Performance Goal

Oversight

Planning and Managing

Implementing Projects

Approves and Monitors

Recommends processes for improvement

Operational objectives to meet goal

Roles

• OESO– Development and implementation of ECMS– Link between OESO activities and ECMS activities– Work with departments to determine potential

compliance issues and develop corrective action plans– Overall regulatory compliance

• Advisory Committee– Provides guidance and recommendations– Reviews ECMS materials and reports– Be an advocate

Roles

• Department/Facility– Work with OESO personnel to determine

compliance issues– Participate in compliance surveys– Implement Corrective Action Plans

ECMS Implementation

• Target specific processes to improve consistent with the overall goal to achieve long lasting compliance

• Implement at a department or facility level

Preliminary Evaluation of Areas with Highest Risk

• OESO did evaluation of risks in a number of areas, taking into account:– EPA audit results – Internal laboratory audits – IECP Compliance audits

Example ScoresRegulation Probability

of ViolationImpact of Violation

Potential Env. Impact

Impact on Public Image

Cost Ease of Implementation

Total

Non-lab waste Practice

3 3 2 2 2 2 14

Aerosol Cans 2 2 1 2 2 3 12

Improve Aerosol Can Management• Compliant disposal of aerosol cans• Change in DENR interpretation to include all

discarded cans

Improve Management of Non-laboratory Generated Hazardous Waste

• Paints, inks, solvents, etc. generated by paint shops, facilities, transportation, grounds, golf course, and gardens

Pilot Selection

• Departments or facilities candidates that generate discarded aerosol cans and/or non-lab hazardous waste – FMD – E&O– Transportation

Pilot Implementation

• Implemented Aerosol Can Recycling Program within E&O and FMD

• Conducting surveys throughout E&O and FMD to determine potential environmental compliance issues

• Developed corrective actions plans for non-compliance issues found during surveys.

• Majority of non-compliance issues corrected and department continued compliance plans implemented

Ongoing Plans

• Expand Aerosol Can Management to additional departments

• Complete surveys of FMD & E&O• Begin survey of Transportation and Dining• Meet with Advisory Committee at least once

per year to review ECMS program and compliance status

Successes & Failures

• Slow process but definitely have upper management buy in – Advisory Committee engaged in process

• Departments understand need for the new system

• Departments are willing to implement or make changes to processes for improved compliance

• Implemented changes to Laboratory Audit Program to ensure environmental compliance